Valuation remand cannot travel beyond the show-cause notice; fresh de novo adjudication based on new parameters fails.

Adjudication and remand directions must stay within the scope of the show-cause notice; a fresh basis for valuation cannot be introduced at the appellate stage. Here, the original valuation dispute was examined against the statutory valuation scheme, a binding Board circular and settled excise valuation principles, but the remand order shifted the matter to a different redetermination basis under the Valuation Rules that had not been proposed in the notice. Because the revised calculations and de novo adjudication travelled beyond the notice, the remand order and the consequential de novo order were unsustainable, and the assessee's appeals succeeded.

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Issues: Whether the remand order could introduce valuation parameters beyond the show-cause notice and whether the consequential de novo adjudication based on those new parameters was sustainable.

Analysis: The Tribunal held that adjudication and appellate directions must remain within the bounds of the show-cause notice. The original adjudication had examined the proposed valuation method with reference to the statutory valuation scheme, the binding Board circular, and the judicial principles governing excise valuation. The remand order, however, introduced a different basis for re-determination under Rule 6 of the Valuation Rules, which was not the basis proposed in the notice. Since the fresh calculations and directions travelled beyond the notice, the subsequent re-adjudication founded on those directions could not stand.

Conclusion: The remand order was unsustainable, the consequential de novo order also failed, and the appeals were allowed in favour of the assessee.

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